Dave,
To expand on this a bit
One of the issues I have is that the person who is driving the vehicle is totally and completely responsible for their own logs – this is one gap. There are a lot of issues with just maintaining the data in a safe and accessible manner with many carriers, some can’t pull basic financial info out of their systems without an act of congress, let alone manage to provide records on demand for the drivers/owners. I get frustrated with some who tell me something can’t be done because they are not trained or understand the systems they use.
The second gap is there are several audits that we have to deal with, the Fed Dot is one – a state audit is another and the IRS is a third. In my case, because my state is trying to capture every penny, I have gotten a notice for an audit from the MPSC, not happy about it but my logs are only one small part of the audit. The point is that for some in a hostile relationship (for what ever reason), the carrier can decide not to provide anything – no legal obligation to do so because logs are not their responsibility.
The third gap is portability, somewhat technical and something that several departments on the federal level have been grappling with for a while – how does one get the data from a disk, CD or electronic file in a format that is acceptable to their auditors or LEA? Practically speaking it is not as easy as just getting a disk, CD or electronic file and printing it – there may be a need to use the data in electronic form for forensic reasons due to an accident or something else. I know one question that can be brought up is the validity of the data itself, just because it comes from the carrier, there is no chain of custody or that the data has not been tampered with.
Another underlying issue is that we will become dependent on electronic logging, the companies will sell the software and services to the carriers and when the time comes to up with data standards and portability, the DOT may not be sympathetic to the driver – remember this is the DOT we are talking about.
This area of IT is/was my specialty long before disaster recovery/business continuity and I know from my Pharma experience I can sit here and point out a lot of problems with these systems.